UPDATE - Corporate Transparency Act – Reporting Deadline on Hold Again
On December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated the stay of the preliminary injunction entered on December 23rd, which would have required reporting companies to comply with the beneficial ownership information ("BOI") reporting requirements of the Corporate Transparency Act ("CTA"). This recent development reinstates the district court's nationwide preliminary injunction that halted enforcement of the CTA, including the requirements to file the BOI reports.
As of December 30, 2024, reporting companies can voluntarily file BOI reports, however, they are not required to file BOI reports while the preliminary injunction is in effect and will not be subject to liability if they fail to file while the preliminary injunction remains in effect.
Reporting companies should continue to monitor the litigation developments and guidance issued by FinCEN. See, https://fincen.gov/boi, " Alert: Alert [December 27, 2024]: Impact of Ongoing Litigation – Deadline Stay – Voluntary Submission Only".
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